New legislation

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15 Dec 2025
Subject Tax updates
Categories Tax

Overview:

European Parliament voted in favour of simplifying the EU Deforestation Regulation ("EUDR")

On Wednesday, 26 November 2025, the European Parliament voted in favour of simplifying the EU Deforestation Regulation (EUDR), originally adopted in 2023. These changes aim to make compliance easier for businesses and stakeholders while preserving the regulation’s core objective: preventing products linked to deforestation from entering the EU market.

Key Measures

1.   Extended Compliance Deadlines:

  • Large operators and traders: New deadline is 30 December 2026
  • Micro and Small enterprises: Extended until 30 June 2027

2.   Streamlined Due Diligence, with the responsibility placed on businesses first introducing products to the EU market.

Next Steps: The European Parliament is set to begin negotiations with the EU Member States on the final version of the regulation, which must be approved by both Parliament and the Council and published in the EU Official Journal before the end of 2025 for the one-year extension to apply. Given the Council’s expressed support for the postponement earlier this month, we anticipate the one-year postponement will be confirmed.

CBAM Delegated Regulation – specific rules related to accredited verifiers of actual emissions

On 20 November 2025 the Commission released a new Delegated Regulation related to the verification of actual emission in the post-transitional phase. Starting 1 January 2026, only accredited verifiers will be authorized to validate the actual embedded emissions reported in CBAM declarations. If the actual values are not clarified, companies need to report default values which in principle results in higher CBAM costs. The Delegated Act specifies the conditions for: 

  • Granting accreditation to verifiers
  • The control and oversight of accredited verifiers
  • The withdrawal of accreditation 
  • Mutual recognition and peer evaluation of accreditation bodies 

Key take aways 

Who accredits CBAM verifiers?

  • Only national accreditation bodies can grant CBAM accreditation.
  • Verifiers must be legal entities accredited for one or more CBAM activity groups (e.g., cement, steel, aluminium, fertilisers, hydrogen, electricity).
  • Existing EU ETS verifiers can apply for an extension of scope, with clear mapping between ETS and CBAM activity groups to prevent starting from scratch.

What must a CBAM verifier demonstrate?

  • Verification activities should be aligned with EN ISO/IEC 17029:2019, plus CBAM-specific requirements.
  • Robust systems for risk analysis, data auditing, sampling, analytical procedures, and physical site visits.
  • Independent review of every verification engagement.
  • Strict impartiality rules:
    o No consulting on monitoring plan design.
    o No conflicts of interest with operators.
    o Rotation of lead auditors after five consecutive years at the same installation.

How are verifiers controlled?

  • Annual surveillance audits and, when necessary, extraordinary assessments by accreditation bodies, including witnessing actual CBAM verification work.
  • Clear grounds for suspension or withdrawal of accreditation (e.g., serious breaches, repeated non-compliance, fraud, or false information).
  • Structured complaints handling and mandatory information-sharing between verifiers, accreditation bodies, competent authorities, and the Commission via the CBAM registry.

Mutual recognition across the EU

  • Member States must recognize verifiers from other Member States once their accreditation body has passed the CBAM-specific peer evaluation process (or received an exemption).
  • If a national accreditation body fails peer review, it must temporarily stop delivering CBAM accreditation services until issues are resolved.

Taric document codes for CBAM published by Irish customs 

The European Commission, together with EU Member States, is working on CBAM-specific Taric document codes to be declared on import declarations. 

On the 11th of November, the Irish customs authorities published the Taric document codes (see table below or eCustoms Helpdesk Notification Ref 24/2025), which are expected to be applied similarly across the EU. 

Why it matters

It is essential to have the correct Taric document codes on import declarations, as there will be a direct link between the import declaration systems and Certex. This process will validate that certain details declared on the customs declaration correspond with details on the CBAM Registry to ensure compliance with the legal requirements for CBAM. If for instance Taric document code Y128 and the CBAM account number are declared, the following will be verified: 

  • The CBAM authorisation associated to the CBAM account number mentioned in the customs declaration exists in the CBAM Registry.
  • The CBAM authorisation associated to the CBAM account number mentioned in the customs declaration belongs either to the importer or to the customs declarant. This check is done based on the data declared in the "Importer Identification Number" field and the "Declarant Identification Number" on the declaration. 
  • The status of the CBAM authorisation associated to the CBAM account number declared in the customs declaration is appropriate for customs clearance (i.e. “Active”)

If this validation is successful, i.e. the CBAM authorisation is active and belongs to the importer or the customs declarant, then the import declaration proceeds and an MRN is issued to the declarant. If this validation fails, i.e. the CBAM authorisation has been revoked or the holder of the authorization is not the importer or customs declarant, then the import declaration is rejected. 
Taric Document Code
Description
Details declared in the "Document produced, certificates and additional references" field on customs import declaration.

Y128

This code is to be used when an importer has been granted a CBAM authorisation and a CBAM account number has been assigned.

TARIC document type code Y128 CBAM Account number

Y238

This code is to be used when an importer has applied for a CBAM authorisation but has not yet been assigned a CBAM authorisation.

TARIC document type code Y238 CBAM Application Reference Number

Y137

De minimis exemption code. Refers to occasional small imports of up to 50 tonnes net mass per importer and year (cumulative threshold). (Does not apply to hydrogen and electricity). 

TARIC document type code Y137

Y135

Exemption Code. Applies to goods to be moved or used in military activities (art. 2(3) of CBAM reg)

TARIC document type code Y135

Y134

Exemption Code. Goods originating in Büsingen, Heligoland, or Livigno (Article 2(4) of Regulation (EU) 2023/956

TARIC document type code Y134

Y136

Exemption Code. Electricity generated or hydrogen originating in the exclusive economic zone or on the continental shelf of a Member State

TARIC document type code Y136

Y237

Goods of EU origin 

TARIC document type code Y237

Update on the customs duty exemption consignments with a value of €150 or less

Currently, shipments with a value below €150 are exempted from customs duties. Initially, as part of the EU Customs reform, the European Commission proposed to abolish the exemption on small consignments in 2028. The new rule was expected to take effect as of 2028 once the EU Customs data HUB is up and running. 

However, due to the increasing pressure on the Customs Authorities and EU businesses, the European Council has committed to abolish this exemption as soon as possible and preferably in the beginning of 2026, until the Customs data hub becomes operational.

Next steps

The abolishment has not yet been formally adopted into legislation. However, businesses importing low value consignments into the EU should take note of this development as the European Council has committed to effectively levy customs duties on goods with a value of €150 or less as soon as possible in 2026. In the coming weeks this transitional solution will be discussed further by the European Council. 

Handling fee for e-commerce imports 

The European Commission proposed introducing a fixed handling fee per shipment to manage the growing volume of e-commerce imports. This measure is part of the planned reform of the EU Customs Code and aims to discourage separate imports of low-value items by making them less commercially attractive.

Key points

  • EU proposal: A handling fee of approximately €2 per shipment is under discussion at EU level, expected to be implemented by November 2026. 
  • National measures: France plans to introduce a €2 fee per low-value item from January 2026. The Netherlands is considering a similar fee for goods up to €150 to prevent a "waterbed effect" (shifting imports to other countries). 
  • Implementation risks: Introducing a national fee by January 2026 could lead to legal challenges and require significant resources from customs and businesses.

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